Last Updated: Oct 14 2023

1. Introduction

Drax is committed to safeguarding your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use the Drax mobile application and services (“Services”).

By using our Services, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Services.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application refers to Drax, the software program provided by the Company.
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Drax.
• Country refers to: Nigeria
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Application.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

What information we collect

We collect two categories of information about you: information you provide and information we collect automatically.

We do not collect information about your racial or ethnic origin, political opinions or membership of any political association, religious or philosophical beliefs, trade-union membership, genetic data, or data concerning a person’s sex life or sexual orientation. 

Information you provide

Registration and Passenger information may include first name, phone number, email, country, and city. Where permitted or required by law, we may collect your selfie image for liveness checks, national ID numbers and social media accounts for safety purposes, as well as emergency contact numbers. Without providing this information you will not be able to use Drax or some of its features. If you wish, you may additionally provide your last name, and profile picture. 

Driver information may include driver’s full name, profile picture, license data and status, information about the vehicle (type, make, model, year of manufacture, color, registration certificate data, license plate, vehicle inspection report, vehicle image), proof of identity, state identification numbers, ID document (including driver license, passport), proof of residency, home address, date of birth, gender, taxation identifier number, relevant insurance, right to work, driving record, payment or banking information, and other documents which may be required by applicable regulation. Where permitted or required by law, we may additionally collect background checks and criminal records information. This information may be processed by authorized vendors on our behalf. Without providing such information, you will not be able to register as a Driver.

User generated content that you choose to upload on Drax, such as comments, ratings, and reviews.

Information in correspondence you send to us may include chat messages, emails with any attachments, recordings of phone calls you make to us and the related metadata. 

Information for promotions. From time to time, we may run car branding, referral and other promotional programs. If you wish to participate in such programs and receive bonuses, payments or other benefits, we may ask you to provide information such as your name, email, user ID, phone number, payment or banking information, home address, social media account, vehicle type and image. 

Information we collect automatically

Location information. We collect users’ location data to enable rides, provide user support, ensure safety, detect fraud, and comply with legal requirements. We collect location information (including GPS coordinates) based on your Drax app settings and device permissions:

–  Passengers: We collect your device’s precise location when the app is running in the foreground (app open and on-screen) and when the app is running in the background (app open but not on-screen) from the time you request a ride until it ends. Passengers may use the app without enabling it to collect precise location data from their mobile devices by directly inputting the pick-up and drop-off address or coordinates into the app.

–  Drivers: We collect your device’s precise location when the app is running in the foreground (app open and on-screen) and when the app is running in the background (app open but not on-screen) in the Driver mode. We may also collect precise location for a limited time after you exit Driver mode to detect and investigate ride incidents.

Transaction information. We collect transaction information related to the services provided via Drax, including amount charged, payment transaction information, date and time the service was provided, route and distance traveled.

Usage information. We collect data about your use of our Platform, such as access dates and times, features or pages viewed, Platform crashes and other system activity. Where you provide express consent we may collect recordings of your in-app activities. We may also collect and use for marketing purposes the data related to third-party services you used before interacting with Drax.

Communications information. We enable users to communicate with each other and with us through the Platform. To facilitate this, we receive data about the time and date of the communications and the content. We may use this data to provide user support and resolve disputes between users, identify violations of Drax rules, ensure safety, and improve our Platform.

Device information. We collect information about the device you use to access Drax, such as your device name, brand and model, user agent, IP address, mobile carrier, network type, time zone settings, language settings, advertising identifiers, browser type, operating system and its version, screen parameters, battery state, and installed applications that can be used for authentication and anti-fraud purposes. We may also collect mobile sensor data, such as speed, direction, altitude, acceleration, deceleration, and other technical data.

User and trip IDs. We automatically assign you a user ID when you create an Drax account, and a trip ID for each trip. 

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Usage Data
• Your Contact List
• Photo

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

How we use your information

We use the personal information for the following purposes:

1. To enable you to use Drax

–  enable users to maintain an Drax account, request and provide services via Drax;

–  verify Drivers’ right and ability to provide services via Drax;

– prevent and combat unsafe or unlawful behavior, fraud and other violations of Drax rules, suspend and deactivate users engaged in prohibited activities;

–  provide user support, handle user complaints;

–  send non-marketing communications (such as invoices, receipts or notifications about your ride);

–  maintain accessibility, security and stability of our Platform, prevent and resolve incidents and technical problems.

Legal basis: performance of our contract with you, necessity to comply with our legal obligations, and our legitimate interest to make Drax a safe space.

2. To improve and develop features and products

–  perform testing, research, data analysis, development and machine learning;

–  collect your feedback.

Legal basis: our legitimate interest to give you the best Drax experience. When express consent is required for certain uses, we will obtain it separately. 

3. To promote Drax

–  send you marketing communications and ads, and make marketing calls to you;

–  provide you with personalized content and advertising on Drax, and on third-party platforms;

–  organize contests, events, car branding and referral programs and other promotions.

Legal basis: our legitimate interest in promoting Drax. When express consent is required for certain forms of direct marketing, we will obtain it separately.

4. To protect rights and comply with legal requirements

–  comply with license or permit requirements, and any other applicable laws and regulations;

–  respond to law enforcement requests, government inquiries, subpoenas, court orders, legal claims;

–  protect the rights and interests of the Drax group, our users, or the public.

Legal basis: necessity to comply with our legal obligations, and our legitimate interests.

How we share your information

With other Users. We share certain information about users to enable the scheduling and provision of rides:

–  Passenger information shared with Driver includes name, profile picture (if uploaded), rating, pickup and drop-off locations, number of trips, offered fare, comments and contact information. In regions where we require Passengers to submit a national ID number, we may also share with the Driver whether the Passenger has submitted this number (but we will not share the ID number as such).

–  Driver information shared with Passenger includes full name and profile picture, information about the vehicle and its photo, location before and during the trip, ratings and reviews, number of trips, age (for certain features) and contact information.

When required to provide Passengers with receipts and invoices, we may share information about the origin and destination of the trip, the total duration and distance of the trip, itemization of the total fare, Driver’s name, taxation identifier number and other information required by law.

If you register with Drax via a referral link, we may share certain information about you, such as your name and trip count, with the user who referred you. This is to enable the referring user to check whether they are eligible for the referral bonus.

For the purposes of services other than the transportation services provided via Drax, we will share the information with other users that is necessary for the provision of such services. 

With service providers. We may share your personal information for business purposes with providers of the following services:

–  payment processing and transaction fulfillment;

–  user and technical support;

–  background checks, identity verification;

–  insurance;

–  cloud storage;

–  content delivery, in-app messaging, in-app calling, push notifications;

–  anti-fraud;

–  advertising, marketing, and analytics (including AppsFlyer, Smartlook);

–  research and surveys;

–  payment of bonuses and provision of other benefits related to our promotions;

–  consultants, lawyers, accountants, auditors, and other professional services;

–  airports.

The following partners process data for their own purposes as independent controllers and we do not control such processing:

–  Google, in connection with the use of Google Maps (see Google’s privacy policy);

–  social media companies (including Meta), in connection with our use of their tools (see Meta’s privacy policies).

Within the corporate group. We may share your information with a parent, subsidiary, or an affiliate of our corporate group as part of our global operations. 

In connection with a business transfer. We may transfer personal information in connection with a substantial corporate transaction in which personal information is among the assets to be transferred. 

For legal reasons. We may disclose your personal information when it is necessary to protect rights and comply with legal obligations.

With your consent. We may share your personal information for other purposes pursuant to your consent or at your direction.

When it is depersonalized. We may share aggregated or otherwise anonymised information which is no longer personally identifying.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that we assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: support@drax.ng
• By visiting this page on our website: https://www.drax.ng#contact

7. Contact Us

If you have questions or concerns about this Privacy Policy, please contact us at hello@drax.ng.